Sample template. This text is a draft to be reviewed by Pelé Academia's legal team and replaced with the official version.
Transparency
Privacy Policy
1. Who we are
Pelé Academia (Resende, RJ, Brazil) is responsible for processing the personal data described in this policy, as data controller, under Law No. 13,709/2018 (Brazil's General Data Protection Law — LGPD).
2. Data we process
Squad athletes (public display): display name, position, age, state, photograph and a short introduction. Following data minimisation, we do not publicly display the full date of birth, hometown or full legal name of underage athletes.
Visitors and interested parties: data provided voluntarily in forms or contacts (for example, name, email and message), as well as technical browsing data.
3. Data of children and teenagers
Part of the squad is made up of minors. These data are processed and displayed in the best interest of the minor and with the specific and prominent consent of at least one parent or legal guardian, which may be withdrawn at any time. The guardian may request the correction, restriction or removal of the minor's data through the channels listed in this policy.
4. Purpose and legal basis
Data are processed to publicly present the project and its athletes, to enable contact with interested parties and to comply with legal obligations. The applicable legal bases include consent, legitimate interest and, for minors, the guardian's consent, under articles 7, 11 and 14 of the LGPD.
5. Sharing
We do not sell personal data. Data may be shared with providers that support the operation of the website (hosting and infrastructure) and with sports partners, always limited to the purpose and with appropriate safeguards.
6. Retention
Data are kept for as long as the purpose or the athlete's relationship with the project lasts, and are then deleted or anonymised, unless there is a legal obligation to keep them.
7. Data subject rights
You (or the guardian, in the case of a minor) may request confirmation of processing, access, correction, anonymisation, portability, deletion and withdrawal of consent, under article 18 of the LGPD.
8. Security
We adopt technical and organisational measures to protect data against unauthorised access and against destruction, loss or alteration.
9. Contact
To exercise your rights or ask questions about this policy, contact Pelé Academia's data protection officer: